Commissioner Of Income Tax ... vs Genpact Consulting Singapore Pte Ltd

ik-157031296 Delhi High Court 11 December 2024 • 20 min read

Judges (2)

Dharmesh Sharma Coram Yashwant Varma Delivered

Counsel (7)

Devansh Jain Counsel Respondent Disha Jham Counsel Respondent Easha Kadian Counsel Appellant Monica Benjamin Counsel Appellant Sachit Jolly Counsel Respondent Sanjay Kumar Counsel Appellant Soumya Singh Counsel Respondent

Parties (2)

Commissioner of Income Tax (International Taxation)-2 Appellant Genpact Consulting Singapore Pte Ltd Respondent

Case Significance

Commissioner Of Income Tax ... vs Genpact Consulting Singapore Pte Ltd is a Delhi High Court decision dated December 11, 2024 (citation: ik-157031296). The Income Tax Department appealed an ITAT order that held proceedings under Section 263 of the Income Tax Act against a Singapore company were bad in law, relating to a share transfer transaction and dividend distribution tax liability. The Delhi High Court dismissed the appeal, finding no substantial question of law and holding that any dividend distribution tax liability would have been on the Indian subsidiary company, not the Singapore entity. The bench comprised Justices Dharmesh Sharma and Yashwant Varma. The judgment was delivered by Justice Yashwant Varma.

Summary

The Income Tax Department appealed an ITAT order that held proceedings under Section 263 of the Income Tax Act against a Singapore company were bad in law, relating to a share transfer transaction and dividend distribution tax liability. The Delhi High Court dismissed the appeal, finding no substantial question of law and holding that any dividend distribution tax liability would have been on the Indian subsidiary company, not the Singapore entity.

What was the outcome of Commissioner Of Income Tax ... vs Genpact Consulting Singapore Pte Ltd?

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-157031296)